EUDR for coffee importers

EUDR Scope · Regulation (EU) 2023/1115 · position as at 1 July 2026

Short answer

If you import green coffee into the EU, you carry the primary EUDR obligation. Green coffee (HS 0901) is in scope [Reg. 2023/1115, Art. 2(1) & Annex I], and as the first person to place it on the EU market you are the operator: you run full due diligence and file the Due Diligence Statement before the beans are placed or clear customs. [Reg. 2023/1115, Art. 4(2)] The obligation sits with you, not your grower and not your roaster customers.

You are the operator — and that is the heavy end

The EUDR follows the goods to the first point they enter the EU market. Import green coffee and that point is you, which makes you the operator that carries the full obligation. [Reg. 2023/1115, Art. 4(2)] This is a different position from the roaster who buys already-imported green coffee from you: that roaster is generally downstream and mostly references your paperwork, whereas you are the one assembling the origin data, doing the risk work and pressing the button on the DDS. [Reg. 2023/1115, Art. 5 (as amended by Reg. 2025/2650)] If you also trade already-placed lots between EU businesses, that trader activity is lighter — but the moment you are the first to bring beans in, the full operator duties attach.

What you file, and when

Before a consignment is placed on the market or released for free circulation, an importer-operator must complete three steps. [Reg. 2023/1115, Art. 8]

Gather the information for every plot the coffee came from: geolocation, harvest dates, country of production and legality evidence. [Reg. 2023/1115, Art. 9 & Art. 2(28)]
Assess and mitigate the risk that the coffee is non-compliant — unless the origin is low-risk, where a simplified route applies (see below). [Reg. 2023/1115, Art. 10 & 11]
File the Due Diligence Statement in the EU Information System and obtain the reference number that travels with the goods and that your buyers will quote downstream. [Reg. 2023/1115, Art. 4 & 33]

Geolocation is the part that trips importers up. You need coordinates for every plot of production, and full polygons for plots larger than 4 hectares — not a mill address or a co-operative name. [Reg. 2023/1115, Art. 9 & Art. 2(28)] With smallholder coffee that can mean thousands of plots behind one container, so start collecting the origin data at the point of purchase, not at the port.

Origin risk tiers change your workload

Where the coffee comes from decides how much due diligence you do. Under Implementing Regulation (EU) 2025/1093 each country is benchmarked low, standard or high risk. [Impl. Reg. 2025/1093]

Standard risk — full due diligence. Major origins such as Brazil and Colombia are standard risk, so you run the complete information-plus-risk-assessment-plus-mitigation cycle. [Impl. Reg. 2025/1093]
Low risk — simplified due diligence. Vietnam is benchmarked low risk, so a simplified procedure applies: you still collect the Article 9 information and confirm negligible risk, but you are not required to run the full risk assessment and mitigation of Articles 10 and 11. [Reg. 2025/2650]
High risk — enhanced scrutiny. Only four countries (Belarus, Myanmar, North Korea, Russia) are high risk and none is a significant coffee origin, but high-risk consignments face higher inspection rates. [Impl. Reg. 2025/1093]

Tiers are dynamic and the first benchmarking review is due in 2026, so an origin's category can move — don't hard-code today's tier into a permanent process.

Green versus instant: watch the pending act

Green and roasted coffee (HS 0901) are in scope today. [Reg. 2023/1115, Annex I] Soluble and instant coffee and coffee extracts (HS 2101) are the subject of the draft delegated act the Commission published on 4 May 2026, which proposes adding them to Annex I. [Commission EUDR implementation page] As at 10 July 2026 that act is not adopted and not in force, and the final text can change. If you import soluble coffee, treat it as an imminent addition and get your origin data in order now rather than waiting for the rule to land.

What this determines — and what it doesn't

Screening your coffee imports tells you that you are the operator, which lots are in scope, your deadline, the origin risk tier and the documentary obligations you owe. It does not verify that any farm behind your beans is deforestation-free — that depends on the geolocation-plus-evidence your suppliers provide and any satellite check. Knowing your position and exactly what to collect from origin is where the work starts.

General information about Regulation (EU) 2023/1115, not legal advice — and not a deforestation assessment. This kind of screening determines your scope, role, deadline and documentary obligations; it does not verify that any plot of land is deforestation-free. Confirm your classification with counsel before relying on it for a market-access decision.

Know exactly what you must file, and for which lots

As the importer you are the operator, so the DDS is yours to file — but which lots, which origins and what data you must collect are rarely obvious across a mixed book. The EUDR position report screens your products against Regulation (EU) 2023/1115, confirms your operator role and deadline, tiers your origin countries, and hands you ready-to-send supplier data-request letters.

Check if my product is caught → get my EUDR position report

Questions

Is a green-coffee importer the operator under the EUDR?

Yes. If you import green coffee (HS 0901) into the EU, you are the first person to place it on the EU market, so you are the operator. You run full due diligence and file the Due Diligence Statement before the beans are placed on the market or clear customs.

What does an importer have to do before the coffee clears customs?

Gather the information for every lot — plot geolocation (coordinates, and polygons for plots over 4 hectares), harvest dates, country of production and legality evidence — assess and mitigate risk, then file the DDS in the EU Information System and obtain the reference number. The reference number travels with the goods to the buyers downstream.

Does the risk tier of the origin country change what an importer must do?

Yes. Under Implementing Regulation (EU) 2025/1093, coffee from a standard-risk origin such as Brazil or Colombia requires full due diligence, while a low-risk origin such as Vietnam allows a simplified procedure — collect the information and confirm negligible risk, without the full risk assessment and mitigation step.

Is instant coffee covered for importers?

Green and roasted coffee (HS 0901) are in scope now. Soluble and instant coffee and coffee extracts (HS 2101) are the subject of a draft delegated act published on 4 May 2026 that proposes adding them to Annex I. As at 10 July 2026 that act is not adopted and not in force, so treat instant coffee as an imminent addition rather than settled scope.

Sources

Regulation (EU) 2023/1115 (EU Deforestation Regulation) — https://eur-lex.europa.eu/eli/reg/2023/1115/oj — Art. 2(1) & Annex I (coffee in scope, HS 0901), Art. 4 & 8 (operator due diligence and DDS), Art. 9 & Art. 2(28) (information & geolocation), Art. 10 & 11 (risk assessment & mitigation), Art. 33 (reference number / EU Information System).
Regulation (EU) 2025/2650 (amending 2023/1115; dates of application, downstream obligations and simplified due diligence) — https://eur-lex.europa.eu/eli/reg/2025/2650/oj — Art. 5 (downstream roasters/traders collect reference numbers); simplified due diligence for low-risk origins.
Implementing Regulation (EU) 2025/1093 (country risk benchmarking) — https://eur-lex.europa.eu/eli/reg_impl/2025/1093/oj — Brazil and Colombia standard risk (full due diligence); Vietnam low risk (simplified); high-risk countries Belarus, Myanmar, North Korea, Russia.
European Commission — EUDR implementation, guidance & FAQ — https://green-business.ec.europa.eu/deforestation-regulation-implementation_en — draft 4 May 2026 delegated act proposing to add soluble/instant coffee and extracts (HS 2101) to Annex I (pending, not in force).